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Interpretation ID: aiam2572

Mr. Robert B. Kurre, Director of Engineering, Wayne Corporation, Post Office Box 1447, Industries Road, Richmond, IN 47374; Mr. Robert B. Kurre
Director of Engineering
Wayne Corporation
Post Office Box 1447
Industries Road
Richmond
IN 47374;

Dear Mr. Kurre: This responds to your April 1, 1977, letter asking whether the hea protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, extend to contactable surfaces 30 inches forward of the seating reference point of the front passenger seat behind the driver.; The head protection zone requirements are outlined in S5.3.1.1 of th standard. This section requires that the zone extend 30 inches forward of the seating reference point. The fact that the requirement may extend the head protection zone into the driver occupant space and thus involve contactable surfaces does not diminish the applicability of the requirements to contactable surfaces within that space. Contactable surfaces within that 30-inch zone, as shown on your sketch, must meet the requirements of the standard.; Sincerely, Frank A. Berndt, Acting Chief Counsel